Implementing the BSSD in the UK Ian Chell Policy Manager Department of Health
Department of Health - Health Protection Our role is protecting public health - In Health Protection, our responsibilities include policy advice on protecting public health from the effects of radiation. This can be effected in many ways such as with regulations but often guidance and stakeholder engagement are the best solution We work closely with Public Health England (was HPA) who provide expert advice 2
Current UK Regulatory Framework for Radiation Protection Complex not easy to explain and wouldn t recommend it as a framework United Kingdom (UK) = England, Northern Ireland, Scotland and Wales Great Britain (GB) = Excludes Northern Ireland (NI) Nuclear is clear cut and requires one regulator for GB (no Nuclear sites in NI). Occupational is GB with separate for NI includes members of the public. However, they also have responsibility for QA and equipment failure = can mean two regulators dealing with the same incident 3
Current UK Regulatory Framework for Radiation Protection Environmental Scotland, Wales, Northern Ireland and England plus Unique regulations in Scotland. Medical Exposures Policy is UK-wide but enforcement is undertaken by 4 different agencies in England, NI, Scotland and Wales. Covers failures in procedures, justification, optimisation etc but not patient over-exposures from equipment failure Nuclear medicine departments are also regulated by the radioactive material transport authority, the medicines regulator for the manufacture of the RMP and are subject to security checks by the police. Administration of RMPs has a set of regulations that are Medicines based. In the future (post BSSD) these will be radiation protection based 4
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Current UK Regulatory Framework for Radiation Protection Validation system in place requires three different requirements for Medical Physics Expert, Radiation Protection Advisor and Radioactive Waste Advisor. The UK takes a global lead in Radiation Protection Expertise The UK regulatory framework needs to be simplified to reduce the regulatory burden especially on healthcare providers The BSSD will be used by DH as a good opportunity to reduce the regulatory burden on healthcare providers and simplify and harmonise where possible 6
BSS and Future UK Regulations Final Stages Once it is set in stone the next stage is to cross reference with existing regulations The make up of the future regulations has not yet been decided but I can assure you all they will be simpler than the current structure Gold-plating review: operation of the transposition principles in the government s Guiding Principles for EU Legislation - BIS website (.GOV) use search DH has policy aims for the current medical exposure regulations with respect to IRMER and MARS but these are over and above the BSS We have concluded that it will be more efficient to revise concurrently 7
Future UK Regulatory Strategy Early stages Significant challenges Problem number one - Stakeholders engage and think outside the box Policy role is to look at it all from a birds-eye view and build a strategy that takes everything into account 8
The BSSD DH policy aims The factors to reduce the burden on healthcare providers Government s new simplification policy Stakeholders:- DH already has good networks in place with professional bodies Transparency:- good way of establishing a broad, professional opinion because the UK has a number of bodies - Other government agencies - need for cross government liaison 9
First Tasks Gap Analysis this correlates current regulation with the BSSD to establish Project plan This helps to establish milestones and describe what we are undertaking in a standardised format. 10
Medical Physics Expert The BSSD requires a competent authority to monitor a validation framework NHS England is already leading an initiative to introduce an MPE framework and can be used as a benchmark for other UK Governments. This is part of the trans-european initiative to harmonize MPE skills across Europe. We intend to wrap the regulatory framework as required by the BSSD around the system that will be put into place to ensure it is as simple as possible. 11
Non medical exposures Aware of most non medical UK experiencing a new wave of sports-related practices Under justification review Athletic performance - fat/muscle - DEXA Premier football Regular DEXA scanning One team has just purchased a CT scanner! Both being investigated occupational? Cricket wrist research is it medical research? Weight loss DEXA useful tool if there are medical implications sports clubs don t appear to be using them at this point 12
Summary We have four years to prepare for the final implementation date As you can see, we need to think and plan carefully to ensure the new regulatory framework is optimised by simplifying areas and accommodating all of the new issues Thank you 13